The Energy Transition Is Already Underway

Lately I've been struck by the number of new groups and proposals calling for America to begin the transition to cleaner energy. We even heard this call from the Oval Office several weeks ago. Yet while there's clearly much more to be done to wean ourselves from our reliance on oil and other high-carbon fuels, I'm baffled by the suggestion that this process didn't actually begin long ago--not just in the last year and a half--with policies and R&D initiatives put in place by at least the previous two administrations. Perhaps it's fashionable to ignore our progress to date, because acknowledging it serves as a reminder that the process will require decades to complete, and that the end-point might not resemble the one we imagined when we began.

Let's start by recognizing that a massive energy transition is already well under way on many fronts, including the development of advanced biofuels, nearly-mature wind power, highly fuel-efficient vehicles, electric vehicles, solar power that's not just a science fair project, and a range of other technologies and policies for reducing oil consumption and greenhouse gas emissions. These didn't just appear spontaneously; most required literally decades of effort to get to this point. So if we're already headed down this path, rather than arguing about starting out should we rather be asking how much we can do now to accelerate this shift?

Take fuel economy, which seems simple, because we all understand miles per gallon, or think we do. But how many people realize that the incremental fuel savings from higher mpg shrink as mpg increases? The chart below shows the annual fuel consumption for a car driving 12,000 miles per year, about the national average, versus fuel economy in mpg. The improvement in Corporate Average Fuel Economy of new cars between 1978 and 2008, from about 20 mpg to 27 mpg, has already saved a very substantial 160 gal/yr per car, while the increase to 34 mpg by 2016, the new CAFE target, will save another 90 gal/yr. However, advancing from there to 44 mpg, roughly equivalent to the 2012 EU target of 130 grams of CO2 per kilometer, would save only an extra 80 gal/yr. That's no reason not to move ahead with more efficient cars, but we must recognize that we've already captured the steep part of a curve that is now flattening out, as the cost/benefit of each successively-harder increment diminishes, unless they burn no oil at all. That's where biofuels and EVs come in.
The Renewable Fuels Standard established by Congress in 2007 calls for a quantity of advanced and cellulosic biofuels by 2022 that exceeds what we currently get from corn ethanol. The problem is that at this point, after many years of hard work developing these technologies, there is not a single commercial-scale cellulosic biofuel facility design that has been built, tested and certified for profitable replication on the scale required, despite a special production tax credit of $1.01/gal. Nor do I conclude that's for lack of the government, private investors and big companies like ExxonMobil, Chevron, Shell, and BP throwing plenty of R&D dollars at the challenge. Within a few years we might be at the point at which billions of extra dollars for advanced biofuels would result in hundreds of such facilities actually being built, but then plenty of experts thought we would already be at that point by now, including the EPA, which had to ratchet back its cellulosic ethanol quota for this year from a level equal to the annual output of one corn ethanol plant to the quantity that a corn ethanol plant produces every three weeks or so.

The prospect for EVs looks more immediate--though still on a relatively small scale--with GM and Nissan launching flagship models later this year. However, as I noted in a recent webinar, every million EVs running entirely on electricity would save 31,000 barrels per day of gasoline, or about 0.3% of our current usage, and that's assuming they would replace cars getting today's average mpg, rather than Prius-type non-plug-in hybrids, as seems likelier to me. It's going to take a whale of a lot of EVs to make a real difference, and it's not yet obvious that offering more than the current $7,500 in consumer tax credits to buy them, or handing out more than the billions that have already been given to car companies--including some that have never built a mass-produced car--is going to put a lot more of these vehicles on the road in the next few years than would happen under existing policies that are still playing out.

However attractive energy visions such as the President's might be, even to me, there are practical limits to additional activism at a point when so many wheels have already been set in motion. I do understand that the nation is riveted by the oil spill, and that transforming this interest into support for a broader energy agenda could be a once-in-a-generation opportunity. At the same time, I worry about an approach that relies on expanding already-unsustainable financial incentives for clean energy deployment at a time when the deficit has taken on the aspect of a black hole threatening to devour our future, energy and otherwise. To see the energy transition really take off, we must reach the point at which the alternatives are unambiguously better/faster/cheaper than oil, or can at least match its cost and convenience in its primary transportation energy uses, and are not merely better for the environment--as important as that is. We're not there yet, but we've clearly already begun the journey.

Energy Outlook will be on holiday the rest of this week and through the July 4th weekend.

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Where's the Peak?

I've been going through the International Energy Agency's new forecast for medium-term oil and natural gas markets, issued yesterday. In contrast to the IEA's warnings of last summer concerning an imminent oil supply crunch, the agency now sees ample supplies to accommodate the level of demand growth it anticipates for the next five years. Yet while this scenario does not envision a peak in global oil supplies before 2015, its components offer ample cause for concern about the growing market power of OPEC and the risk of geopolitical disruptions. It also signals the growing importance of non-traditional sources of liquid fuels, including natural gas liquids (NGLs) and biofuels, which are included in the IEA's oil supply & demand balance.

The headline features of the IEA's oil forecast include continued growth in global oil capacity from 91 million barrels per day (MBD) in 2009 to 96.5 MBD in 2015. This is driven by the growth of OPEC's capacity, the NGL output of a global natural gas expansion that the US shale gas boom has accelerated, and increased production of ethanol and other biofuels. IEA sees this combination as more than sufficient to counteract a roughly 3.5% annual decline in the output of existing oil fields, including a peak and net decline in non-OPEC production within the next year or two. The latter won't surprise anyone who's been following the Peak Oil issue, but it's all the more worrying when you consider that it doesn't include the impact of project delays owing to the on-again, off-again US deepwater drilling moratorium, which the administration seems determined to switch back on.

This picture is fraught with risks and vulnerabilities, including the prominent role of Iraqi oil revitalization projects, which appear to account for half of the growth in OPEC crude oil capacity in the period. Although there's ample scope to stimulate more output from Iraq's mature fields, and the potential of its undeveloped fields represents the largest conventional oil opportunity in the world, none of it will come to fruition if the county doesn't remain quasi-stable. This might be one area in which the reassignment of General Petraeus to Afghanistan from his CentCom post, where he retained oversight of the Iraq security situation, might not look so positive.

Then there's that shift toward NGLs and biofuels, including the IEA's somewhat surprising prediction that while biofuels will continue to grow globally, the rate of growth will slow, with US output reaching a plateau long before it has attained the targets of the Renewable Fuels Standard. They also appear to be even more skeptical than I am that cellulosic ethanol is on the verge of scaling up rapidly. The larger problem is that both of these sources constitute what I would call "hamburger helper" for oil. Neither ethanol nor first-generation biodiesel (FAME) constitutes an effective gallon-for-gallon substitute for petroleum products, except in blends limited by both infrastructure and legacy vehicle fleets not equipped to handle more than small percentages of these fuels. NGLs provide propane and butane essentially indistinguishable from crude-sourced LPG and just as useful for petrochemicals and heating fuel, but they yield much less in the way of gasoline components, and the ones they do require significant processing to boost their octane, now that tetra-ethyl lead is out of the picture.

On the demand side, things look pretty much as we'd expect in the aftermath of a global recession that hit the developed world harder than the big developing countries--BICs, if not BRICs. As was true before the financial crisis, however, the Middle East contributes the second-biggest source of new demand, after Asia. That means continued growth in domestic demand within some of today's largest oil exporters. Even if that doesn't lead to "peak exports", it buttresses the fundamental shift in global market power underpinning a forecast that might otherwise appear calming to markets.

Anyone looking to the IEA for signs of an imminent peak in global oil supplies won't find it in their Medium Term Oil and Gas Markets 2010 report. What I see instead is a continuation of the world we are already in, with OPEC holding the trump cards. Traders tend to focus on the weekly fluctuations of oil market inventories and indications that supply or demand may grow or shrink in the months and years ahead. Yet while the release of this report, together with another build in US crude inventories this week, reportedly contributed to the $2/bbl drop in oil prices in the last two days, these reactions seem oblivious to a larger reality. With more than 5 million barrels per day of OPEC production capacity shut in, the main reason that oil is trading in the mid-to-high $70s, rather than the mid-to-high $40s, is that OPEC is functioning as a truly effective cartel that is much happier with higher prices. Politicians looking for another economic stimulus might consider the anti-stimulus that oil prices are currently providing, and the consequences of policies that could hand even more power to OPEC in the short-to-midterm.

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Revulsion vs. Hard Choices

I don't know anyone who could gaze at the images of oil-slimed pelicans, gulls, and sea turtles and not feel revulsion and regret. Yet beyond the urgent need to plug the gushing well, protect the coastline and fisheries, and restore the Gulf Coast environment as rapidly as possible, we cannot allow our entirely appropriate emotional response to this tragedy to overwhelm our judgment. As bad as this spill is, our long-term challenges of energy security and climate change remain worse. We would only compound the damage if we allowed our reaction to this spill and its ripples beyond oil to further confuse our energy policies.

In his column in yesterday's Washington Post, Robert Samuelson sharply criticized the President's effort to harness the public's frustration and outrage against the spill into support for his energy and climate change agenda. Mr. Samuelson raised some very salient points concerning the difficulties of attempting to reduce our consumption of fossil fuels at the same time we must meet the expanding energy needs of a growing economy and population. However, I think he missed the deeper contradiction that has been created by the "strange bedfellows" coalitions that have formed since the middle of the last decade, marrying concerns about climate change to the urgent necessity of improving our energy security. As long as the shared enemy was foreign oil--from "countries that don't like us"--these groups could emphasize the overlaps in their positions and mostly ignore the resulting inconsistencies. But with the reaction to the spill turning the political tide against domestic oil as well as the imported kind--and perhaps, by extension, against natural gas derived from the hydraulic fracturing of shale reservoirs--the convenient overlap between climate policy and energy security could vanish.

If that sounds counter-intuitive, perhaps it's because so much of what we've been told by our leaders concerning our energy options has ignored the fundamental mismatch of scale between fossil fuels and our rapidly-growing renewable energy sources. Consider that while US ethanol production has grown by an astonishing 660% since 2000--an average of 23% per year--it still equates to just 2.4% of our annual oil consumption. Non-hydropower renewables, including wind power, which has grown by an even more remarkable 34% per year since 2000, made up just 3.6% of US electricity supply last year. These facts are crucial to the debate, not because these energy sources should be regarded as inconsequential, but because at their current and anticipated near-future output renewables provide a form of energy currency that can only be spent once. If we want to expand wind, solar, geothermal and biomass power to reduce the greenhouse gas emissions from coal-fired power generation, we cannot spend them again on powering electric vehicles to displace petroleum-based transportation fuels. If we want to leverage biofuels to back out imported oil, we can't spend the same biofuels to take the place of oil we won't be getting from offshore wells we aren't drilling. Someday, biofuels and renewable electricity sources may have grown enough to take on all comers, but that day remains over the horizon. And while nuclear power is already contributing on a much larger scale, its expansion will take many years, particularly if we begin retiring older nuclear power plants like Vermont Yankee in the interim.

Natural gas operates in a similar realm of hard choices, though on a larger scale. It currently accounts for nearly one-fourth of our total energy consumption. Last year, with electricity demand down and gas prices at less than half their level of just a few years ago, natural gas-fired power generation made significant inroads into the market share of coal-fired power. That was good for consumers and good for the environment, but it was only possible as a result of the dramatic resurgence of US gas production from the development of shale gas supplies. Together with coal bed methane and gas from tight sands, these unconventional sources now make up half our domestic natural gas output. Yet as with renewables, if we want to use this additional gas to reduce the 40% of US CO2 emissions coming from the power sector, we can't employ the same gas to displace gasoline in cars or diesel in trucks. And without the contribution of shale gas made possible by "fracking", gas would likely be too expensive to substitute for either oil or coal.

We have a wealth of new and old options for addressing both our greenhouse gas emissions and our reliance on imported oil. However, at this point that bounty of choices does not extend to backing out all oil while still reducing emissions. With biofuels and renewable electricity already fully committed to our established energy priorities, our only large-scale option for foregoing the enormous energy resources embodied in the deepwater oil reservoirs of the Gulf Coast--other than simply ramping up oil imports--would require converting coal into liquid fuels. We have off-the-shelf technology to do this, but unfortunately not yet to contain the large increase in CO2 emissions that would accompany such a strategy. Perhaps before we commit ourselves to anything beyond the shortest suspension of deepwater drilling necessary to ensure that it can proceed safely, we should clarify what our national energy priorities really are. A change in the implicit direction in which we've been heading could have far-reaching and enormously expensive consequences, including for the environment.

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Expand the Presidential Commission on Deepwater Horizon

Amid the other news this week, including the President's address to the nation on the Gulf Coast oil disaster and his meeting with BP officials yesterday, the announcement on Monday of the five remaining members of the Presidential Commission to assess the "environmental and safety precautions...to ensure an accident like this never happens again" seems to have sunk without a trace. I don't recall seeing it mentioned in either the Washington Post or Wall St. Journal. I ran across it in the New Orleans Times-Picayune online last night. Yet it's clear that the staffing of such a commission has an enormous influence on its approach and ultimate findings, and on both counts I am seriously concerned. From my review of their published bios, I cannot discern that any named member possesses any direct training or experience with the technology and practices of offshore drilling, a field that in its own way is every bit as complex as aviation, terrorism, or other past subjects of similar commissions.

The gold standard for Presidential commissions investigating accidents of national importance was set by the Rogers Commission on the explosion of the Space Shuttle Challenger shortly after its launch on January 28, 1986. The commission--not just its technical staff--was packed to the rafters with figures of national prominence and deep expertise in aviation and space technology and operations. Headed by former Secretary of State William P. Rogers, it included Neil Armstrong, the first astronaut on the moon, Dr. Sally Ride, first American woman in space, Gen. Chuck Yeager, first pilot to fly faster than the speed of sound, Gen. Donald Kutyna, an expert on spacecraft launches and accidents, and Joseph Sutter, the "father" of the Boeing 747, along with an aeronautical engineering professor, an aircraft designer, a solar physicist, and several other leading experts on aerospace matters. Last but never least was Richard P. Feynman, Nobel Prize-winning physicist, quintessential iconoclast, and perhaps the smartest and most inquisitive human being ever to walk the earth, with the possible exception of Albert Einstein. It was, of course, Dr. Feynman whose famous ice-water experiment with the solid rocket boosters' O-ring material uncovered the root cause of the disaster.

Each of the fine individuals President Obama has named to the Deepwater Horizon Commission brings valuable experience and an important perspective, including that of a professional environmentalist, biological oceanographer, an accomplished physicist and manager of science, and a pair of lawyers with past experience in various aspects of the Exxon Valdez spill and cleanup. I have no objection to any of them individually. However, collectively they are not a patch on the Rogers Commission.

The obvious solution to this problem is that the President should immediately expand the commission to include at least two additional members, and preferably four, with deep expertise and experience in oil & gas drilling, geoscience, and offshore industry operations. It is absolutely essential that the commission includes people who understand not just the ocean environment, but also subsea geology, drilling technology, and relevant oil & gas industry practices, first-hand. They should of course have no connections to BP or to any other company that stands to lose or gain from the commission's findings. While that might narrow the field somewhat, it would not rule out the faculties of the leading petroleum engineering and geosciences university departments, or a wide swath of recently-retired experts in these fields. The US is blessed with abundant expertise in this area, and it would be a crime to exclude it from this vital study.

Despite a nearly universal desire to accelerate our shift away from petroleum in the wake of this disaster, we are nowhere near being able to turn our backs on either the energy or convenience we get from oil. As I've shown in a series of postings since the accident occurred, offshore drilling is a crucial component of US domestic energy supplies, and no current alternative energy source operates at either the scale necessary to replace it, or in sufficiently direct substitution for the transportation energy of which oil is our principal provider. The less oil we produce domestically, the more we will have to import.

In this context it is of the highest importance that the commission be given the best chance possible to interpret the findings of the technical investigations of what went wrong on the Deepwater Horizon rig, and to determine how to structure an approach to offshore drilling that reduces the risks posed by human error and technical failures to the maximum degree possible. Every member of the commission has important contributions to make in this regard, but without the match between relevant experience and the nature of the problem exemplified by the Rogers Commission, the Deepwater Horizon Commission will be operating at least partly in the dark.

I don't often urge my readers to take action on the subject of one of my blogs, but in this case, if you share my concerns about the omission of critical experience from the staffing of this commission, you should contact the White House and your Representatives in Congress to express that view.

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Walruses and Wake-Up Calls

I just finished watching today's hearing on offshore drilling operations and safety by the Energy and Environment Subcommittee of the House Energy & Commerce Committee, featuring the CEOs of ExxonMobil, Chevron, and ConocoPhillips and the US heads of Shell and BP. Rather than giving in to the temptation to deliver a rant on the current level of dysfunction in Congress, I want to highlight a few things that stood out for me in the testimony of the assembled chiefs of the largest oil companies in the US, and then focus on the central dilemma that was explored in the hearing.

1. Although couched in careful language referring to the importance of completing the full investigation of the circumstances involved, the heads of the other companies came as close as anyone could reasonably expect to saying that BP's well design for Macondo and the processes for drilling it would not have passed muster in their companies.
2. A series of very interesting questions focused on the prevalence and effectiveness of "stop-work" policies, in which any employee or contractor on a rig can call a halt to drilling if he or she sees something that looks dangerous. BP indicated it had such a policy in place on Deepwater Horizon. However, John Watson, the CEO of Chevron (in which I own stock) pointed out that in order for such policies to be credible, employees who exercise that initiative must be recognized and rewarded. After all that we've learned about the warning signs on this well, I suspect I'm not alone in having difficulty imagining a "stop-work" call having been welcomed in this case. Corporate culture matters.
3. In one sentence, ExxonMobil CEO Rex Tillerson calmly demolished the half-baked notion that every deepwater well be required to have a relief well drilled in parallel, just in case it would be needed. (This was done in such a low-key way that the questioner didn't seem to grasp what had been said.) Instead of mentioning the doubling of cost involved, Tillerson pointed out that this strategy would double the risk of every project. The risks of a parallel relief well would be the same as for the exploration well, because it would be another exploration well.
4. Sometime later Congressman Scalise from Louisiana picked up on this theme with a question that should have galvanized the room, but somehow didn't. He asked BP North America President Lamar McKay if the relief wells at Macondo were being drilled to the same plans as the blown-out exploration well. Answer: yes, with oversight at every step of the way.

I'm sure I'm neglecting other important comments, though I'm also dismissing the first hour-and-a-half of the hearing, which was frittered away in a blather of posturing and wild "gotcha" chases involving extinct Gulf Coast walruses and dead experts' telephone numbers. But despite all of this, I thought the crux of the problem concerning how to address the other Gulf Coast deepwater leases came through in some astute questions and surprisingly candid answers. Many of the members recognized the importance of the resources involved to the economy of the region and to the energy and national security of the country, and the serious damage that the drilling freezes are inflicting. At the same time, they highlighted the breakdown of the public's trust in the industry to extract these resources safely, despite the statistical evidence that, with 14,000 deepwater wells drilled globally, the Macondo well stands as an anomaly at a single company. The industry representatives also made it very clear that the primary defense against the effects of uncontrolled blow-outs such as this one lies in prevention, rather than clean-up, for which the industry was not adequately prepared to handle a spill on this scale. That's a situation that can't be rectified within six months, and possibly not six years, though the innovations and inspiration coming out of this disaster ought to provide a substantial kick-start to bringing spill-response into the 21st century.

That leaves our government with a monumental dilemma regarding the resumption of offshore drilling. One answer is the total risk avoidance of the current freeze, which appears politically motivated, but for which its supporters might point to some of today's testimony. Unfortunately, the freeze will inevitably increase our reliance on imported oil, because as much as we recognize the need to move in the direction of renewable energy and other alternatives, there is currently no other meaningful substitute for the oil that we now get from deepwater, unless we are willing to consider the risk tradeoffs involved in targeting new domestic oil production on onshore and shallow-water resources that are presently off-limits, such as those in the Arctic National Wildlife Refuge. Another, admittedly riskier solution would be to allow companies other than BP, using designs and procedures in conformance with the industry guidelines developed by the American Petroleum Institute and broadly similar to those just recommended by the Department of Interior, to resume drilling on projects already under way, while the investigations and Presidential commission determine the longer-term measures appropriate for new leases. I lean strongly toward a selective resumption, but the responsibility involved is literally awesome and properly resides with our elected leaders.

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Europe's Oil Price Spike

In our relentless focus on the excesses of the financial sector, many Americans have forgotten that the severe recession we've just experienced was at least exacerbated, if not partially caused by an oil price shock. Now it might be Europe's turn, as the Euro continues its slide against the US dollar. It's a fairly obvious point that a weakening Euro increases the cost of all commodity imports into the EU's Eurozone, while reducing the effective revenue for any exports made with them. Yet when the import is oil, the effects go beyond international competitiveness.

Oil prices have roughly doubled in dollar terms since their low point in January 2009, but they have gone up by an extra 25% in Euros per barrel over the same interval. The divergence this year is even more striking, as the Euro retreats from its highs of last December. Since January 1, oil is up by nearly 6% in €/bbl but down by nearly 12% in $/bbl, as shown in the chart blow. A further retreat to Euro-dollar parity would see the Eurozone's businesses paying nearly as much for oil in their own currency as they did in September 2008, the last time the US saw prices over $100 per barrel.



The previous strength of the Euro partially insulated the Continent's businesses and consumers from the worst oil-price pain of the first half of 2008. When oil reached its all-time high of $145/bbl in July of that year, it was barely over €90/bbl. Then, as oil prices ebbed, the strong currency/weak oil combo provided a substantial economic stimulus to Europe lasting well into 2009, with oil averaging just €44/bbl last year, compared to $62 here.

The shoe is on the other foot, for now, as Europe enjoys little of the recent weakening of oil prices from levels above $80/bbl, while experiencing a mini-spike since the start of the year. And with various pundits suggesting the Euro still has a ways to fall, Europe could be facing oil prices over €70/bbl, instead of the roughly €60/bbl for which UK Brent Crude effectively trades today. That would compound the fallout from the EU's fiscal crisis and amplify the risk of a double-dip recession, perhaps even globally.

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Emissions Twilight Zone

The defeat yesterday of a Senate resolution to rein in the application of the Clean Air Act to greenhouse gas emissions, together with the recent announcement by Senator Lindsey Graham that he would vote against the climate bill he helped Senators Kerry and Lieberman to draft, puts US efforts to deal with climate change into a sort of Twilight Zone, in which the widely-preferred approach of most of those wishing to tackle our emissions directly sits on the sidelines, while EPA regulations that were allegedly intended mainly to scare Congress into passing a climate bill this term now look nearly certain to take effect next year. No one on any side of the issue should rejoice at this outcome.

I confess that I haven't found the time to give the Kerry-Lieberman draft climate bill the same degree of scrutiny that I applied to the Waxman-Markey bill that the House of Representatives passed last summer. Based on the summary that I have read, K-L appears to address at least some of the serious flaws in Waxman-Markey, though the devil is often in the details of provisions such as restrictions on who would be allowed to trade emissions permits. In general, I'm pleased that more of the revenue from emissions permits would flow back to consumers and taxpayers under this bill than in the House version, and less would be diverted to favored constituencies or outright pork. That should reduce the net burden of emissions restrictions on the economy as a whole, a crucial concern when the recovery is still fragile. However, the inclusion of offshore drilling provisions that look to some like an endorsement of a practice that has become hugely controversial since the Gulf spill, but that from my reading could shut down most offshore drilling permanently--a conclusion Senator Graham now seems to share--has probably derailed the bill's chances for passage this year.

So without a legislated cap on emissions and a market-based mechanism to distribute the cuts to those parties with the greatest capacity to achieve them at the lowest cost--the essence of the "trade" portion of cap & trade--the EPA will now determine where and how emissions should be cut. That is the least-efficient way to go about this that I can imagine. It's even a mixed blessing that the EPA's "Tailoring Rule" would initially focus application of the Clean Air Act on new or expanding facilities adding large quantities of GHG emissions--one dimension of economic growth--rather than on all existing facilities, though the latter seems to be on tap for Step 3, due in 2013. As described, Step 3 would apply to any facility emitting more than 50,000 tons per year of CO2 equivalent GHGs. That's a lot more than your local pizza shop or most small businesses, but it's not quite as small as it's been portrayed. 50,000 tons is roughly the CO2 emissions from a business or facility consuming a mix of energy equal to two tanker trucks of gasoline or diesel fuel per day, or 9 Megawatts of average US grid electricity around the clock.

One of the ironies of the situation is that anyone now opposing legislation putting a price on carbon because they're not convinced of the risks of climate change is effectively supporting the EPA's approach to emissions. Perhaps that just means that they see the current Congress as a high-water mark of support for aggressive action on climate change and suppose that a future Congress--say, after November's mid-term elections--would be more willing to take the EPA out of the climate change business. Nevertheless, at least for now, the alternative to legislation like the Kerry-Graham bill is not inaction, but command-and-control regulations that could be much more damaging to a weak economy.

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